Commentary on the 2006 Environmental Assessment for "Refinements" to the World Trade Center Memorial and Redevelopment Plan

By Louis Epstein
R.D. 2,Carmel,New York 10512
Founder & Director,World Trade Center Restoration Movement

The latest "Environmental Assessment and Finding of No Significant Impact and Determination of Non-Significance" is just another milestone of narrow-minded incompetence in the tragicomically wretched official planning process for rebuilding the destroyed World Trade Center.

It merits only another "Finding of No Significant Improvement" by the tinkerings the Assessment attempts to excuse.

The notice sent out by Stefan Pryor on the day he left for another job baldly claims "Implementation of the Approved Plan began with the formal groundbreaking for Freedom Tower on July 4,2004." Of course all that happened that day was the laying of one stone at an obsolete location from which it has been removed.

The rest of the document,as has been the hallmark of the official planning process from inception,engages in similar hoodwinking and self-congratulation over the horrifically inappropriate "Proposed Action" of the FGEIS that became an "Approved Plan" only by the action of those who had proposed it...not by submission of the proposal to someone else with the power to demand better.And the public's attempts to demand better have been systematically ignored for years.

This document is just the latest of many demonstrations of the catastrophic consequences of allowing the organization long aptly nicknamed the "Leave Manhattan Destroyed Committee" to act as both proponent of plans and regulator of those plans.The crying need for an outside authority to force the products of this incompetent process to be abandoned immediately remains unmet. One message stands out crystal clear to everyone except the plan's promoters:

"End it,Don't Amend it!!"

No amount of tinkering can turn the current plan into something worth building;no plan that meets the indefensible programmatic requirements that plan was commissioned to meet can be something worth building;no plan that seeks to fulfill the inappropriate priorities that gave rise to those requirements can be something worth building.

There is no use in officialdom shifting the blame for those requirements to public opinion;public dissatisfaction with the proposals put forward by the official planners has been a constant throughout the process. We must never forget that in the official public poll the Libeskind plan finished last,and "Neither" (of the two "finalist" plans bad enough to meet the official requirements) was the clear winner,indicating public dislike for the guidelines that gave rise to those plans.

As just one example,the current document defends removal of the oil/water separation filter at the proposed intersection of Fulton and Greenwich Streets...given the unanimous opposition to Greenwich Street being extended through the World Trade Center site when the Project for Public Spaces opened a comment board on the subject,why should there even be such an intersection?What is so precious about the potential to drive truck bombs down the new streets close by each one of the proposed structures...and discrediting all claims of resilience by ensuring that no new office towers can even be on the same block as the old?

A plan that deliberately erases the identity of the World Trade Center site by carving it into blocks no longer distinct from the surrounding neighborhood,that ostentatiously showcases the permanent power of the murderers of thousands to prevent us from ever rising again, that dares not reclaim the full height of the destroyed iconic Twin Towers, can not be turned into a good plan,or even a tolerable one,by amendment.

You can not build a viable plan based on the "Findings of the FGEIS" which readers of that document know are as a rule highly flawed. The FGEIS failed spectacularly to defend the General Project Plan's overwhelming inferiority to the unfairly caricatured Restoration Alternative,the ideal rendition of which alternative should always have been the entire mission of the redevelopment planning process.

Mr. Pryor has claimed there is no reason to revisit the erroneous decisions made in this planning process when in fact there was and is no reason to revisit the decisions made in the 1960s in planning the original complex,such as removing the archaic street grid and creating a site with a distinct identity...the only revisions that need to be made are in updating the engineering of undiminished Towers.

The project plan fails economically,it fails symbolically, it fails spiritually,it fails aesthetically.

"End it,Don't Amend it!!"

When you are going downward,the only way upward is to go backward.

The only plans worthy of the site are ones that do not fail in the way that the official plans have been ordered to fail.

We need plans that honor the distinct character of the Financial District,not seek to transform the area into yet another of the city's countless "24/7 communities" and encourage the already overheated pace of population growth.

We need plans that honor the distinctness of the World Trade Center site itself,retaining its clear definition among the surrounding areas rather than opportunistically dividing the "superblock" because of changing fashions and taking the needed de-vehicularization of lower Manhattan a giant step backwards.

And most of all,we need plans that are centered on gigantic Towers that show no retreat in the face of mass murder,no retreat from the spirit that gave us the originals,and create the only historical and urban context that can make a memorial on the site honor the victims more than it honors the killers.

The turning of resolutely deaf ears to the public clamor for restoration of what was destroyed must end.

Let us instead turn deaf ears to those who plead real estate economics,remembering that it was strictly through having the courage to ignore short-term demand that the greatest buildings of New York achieved iconic stature.They became exceptional exactly because they were "too big"...and in the end made more money than they possibly could have otherwise!

Let us instead turn deaf ears to those who plead fear,recognizing that to show the success of the killers in inspiring such fear encourages them to strike again,and that the engineering facts make clear that supertall buildings are necessarily the safest.

Let us instead turn deaf ears to those who see the murder of thousands as a lucky chance to impose their tastes in urban design on a site that met the tastes of others,and reject both their insensitivity and the symbolism of being made to change our course by those who would kill us.

Let us see with open eyes the importance of not allowing this site to change more than can be avoided,and the empowerment of mass murderers that any such changes represent.

Let us show that the spirit that gave us the Twin Towers did not die and can not die,rather than build a tomb for it amid stunted symbols of surrender.

Let us build awe-inspiring engineering marvels that reincarnate that spirit for the new millennium on a scale greater than before and alone can show that the killers did not "cut us down to size".All the sacrifices made by our forces abroad are revealed as empty bluster if in the end all that rises again are smaller buildings angled in fear away from empty holes where the symbols of our pride once stood.

We didn't shrink from fully rebuilding the Pentagon stronger than ever, New York must show it is made of no less substance than the countless cities that have rebuilt their wounded hearts fully after devastation by war or disaster.

I have said all this and more before,and will say it again at every opportunity;these truths do not change.

I can only close by repeating what I have said previously when confronted with attempts to "amend" the Libeskind plan:

The case for complete abandonment of the current plans in favor of ones much more evocative of what was destroyed in the attacks of September 11th 2001 has never been clearer.


September 24,2006